HUMAN RESOURCES PRIVACY POLICY

FOR PERSONAL DATA PROTECTION (EMPLOYEES AND JOB CANDIDATES)

As the Human Resources Department of 2A MÜHENDİSLİK SAN. VE TİC. A.Ş., we attach utmost importance to the protection and lawful processing of Personal Data in accordance with Law No. 6698 on the Protection of Personal Data (KVKK), and we act with this diligence in all our planning and activities.

We do not evaluate the protection and processing of Personal Data, which is the foundation of privacy, solely in terms of regulatory compliance; we place the value we give to people at the core of our approach.

With this awareness, as the Human Resources Department, we take all administrative and technical measures for the protection and processing of Personal Data. Work is being carried out to raise employee awareness to ensure compliance with the policy, necessary orientation processes are implemented for new employees, and necessary arrangements are made.

What Are Examples of Your Personal Data?

Full Name, Home Address, Email Address, National ID Number, Driver's License Number, ID Serial Number, Fingerprint, Date of Birth, Place of Birth, X-ray, MRI and similar records, Blood Type, Phone Number, Country, City, Postal Code or District, Age, Gender, Criminal Record, Health Records, Bank Account Number, Resume, CV, Academic Information, Marital Status, Information about Children, Emergency Contact Information, Disability Status, Military Records, etc.

What Are the Purposes and Legal Bases for Processing Personal Data?

Our company processes personal data for both job candidates and employees for the following purposes:

  • Establishment and performance of employment contracts
  • Determining candidates' suitability for positions, verifying references and competencies during recruitment
  • Performance of payments and benefits
  • Monitoring employees' claims arising from labor law
  • Organizing training programs
  • Conducting performance evaluations
  • Evaluating qualifications required for a specific job or task
  • Disciplinary investigations, evidence collection, and termination of employment contracts when necessary
  • Establishing contact in emergency situations
  • Fulfilling the company's obligations arising from labor law legislation
  • Executing core human resources processes
  • Ensuring the security of data collected by the company
  • Monitoring compliance with company policies

Methods of Collecting Personal Data

Your personal data is collected by our company through: job application forms, CVs you have shared, job applications made through our website, job applications received through consultancy services and advertisements, filling out forms defined in our procedures by our HR department, employment documents you provided during onboarding, forms filled during training, AGI Forms, daily PDKS records including passwords, fingerprints and attendance forms, and HR forms filled out as a result of requested notifications.

Sharing Your Personal Data with Third Parties

For your security and to fulfill our company's legal obligations, your personal data may be shared with relevant institutions or organizations to the extent permitted and required by the Labor Law, Occupational Health and Safety Law, Social Insurance and General Health Insurance Law, Turkish Commercial Code, Law No. 6698 on the Protection of Personal Data, Identity Notification Law and other legislation provisions, including but not limited to: Personal Data Protection Authority, Ministry of Finance, Ministry of Customs and Trade, Ministry of Labor and Social Security, Turkish Employment Agency (İŞ-KUR), Information Technologies and Communication Authority.

Specific Data Sharing Examples:

  • Payroll Processing: Processed in Canias ERP accounting program for payroll operations and data updates
  • Consultancy Services: Shared with consulting firms and private employment agencies for R&D incentive calculations
  • Health Services: Health data shared with workplace physician for treatment and health checks
  • Audit Activities: Payroll information transferred to company auditors
  • Security: CCTV recordings may be transferred to law enforcement in case of incidents
  • Legal Proceedings: Shared with lawyers and relevant institutions for legal defense
  • Business Operations: Data shared with affiliated companies, insurance companies, travel agencies for health insurance, travel, accommodation, visa processes

Sharing Personal Data with Third Parties Abroad

International Data Transfer:

With your consent, your personal data may be shared with third parties abroad for communication during international travel and training, travel organization, and bulk email sending.

How Are Personal Data Stored and Protected?

  • Your personal data will be stored confidentially in our company's database and systems in accordance with Article 12 of KVKK and will not be shared with third parties except for legal requirements and the regulations specified in this document.
  • Our company is obliged to take software measures such as access management and physical security measures to prevent unlawful processing of personal data, prevent unauthorized access to systems and databases containing your personal data, in accordance with Article 12 of KVKK.

How Long Are Personal Data Stored? 10 YEARS

Your Personal Data will be stored by us at all times during your employment, taking into account the periods defined in relevant laws, and for 10 years after your departure.

What Are Your Rights Under Article 11 of KVKK?

In accordance with KVKK, by applying to our company, you have the right to:

  1. a) Learn whether your personal data is being processed
  2. b) Request information if processed
  3. c) Learn the purpose of processing and whether it is used appropriately
  4. ç) Know the third parties to whom it is transferred domestically/abroad
  5. d) Request correction if processed incompletely or incorrectly
  6. e) Request anonymization or deletion within the framework of Article 7 of KVKK
  7. f) Request notification of operations performed under items (d) and (e) to third parties
  8. g) Object to consequences against you due to analysis exclusively by automated systems
  9. ğ) Request compensation for damages if you suffer harm due to unlawful processing

How to Apply Regarding Your Personal Data?

For situations related to your Personal Data defined in this policy, you must apply:

  • In Person: With ID verification
  • Via Notary: Through notary public
  • By Email: To [email protected] with KVKK HR Application Form (signed and scanned)
  • In Writing: To Human Resources Department with KVKK Application Form

Application Response Time 30 DAYS

Your request submitted via petition or email will be responded to within 30 days through the same communication channel.